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FCPA Compliance and Ethics Report-Episode 124, The Oscars and Compliance, Part I with Jay Rosen [Video]

In this episode I begin a five-part series on the Oscars and Compliance with recovering Hollywood screenwriter Jay Rosen. In this Part I, we review the process by which films are nominated for the Oscars and the campaigns...more

FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras [Video]

In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more

2015 Trends: #5 Regulatory Enforcement Moves Down Market

While ethics and compliance scandals that implicate brand name companies tend to grab the headlines, smaller organizations have always borne the brunt of regulatory enforcement. Over the years, U.S. Sentencing Commission data...more

FCPA Compliance and Ethics Report-Episode 121-FCPA Year in Review, Part II [Video]

In this episode I review the two Opinion Releases, Esquenazi court decision, DOJ communications via speeches on FCPA enforcement. I end with a look at 2015. ...more

OECD Foreign Bribery Report: Leveraging The How, Where And Why Of Bribery To Bolster Your Ethics And Compliance Training Program

In my last blog post, “The OECD Foreign Bribery Report: 7 Insights To Improve Your Ethics And Compliance Training Program,” I identified the seven bribery trends covered in OECD’s Foreign Bribery Report. The report listed...more

Financial Institutions and a Lack of Ethics

If there is one industry that needs an ethics overhaul, it has to be the financial industry. The list of transgressions continues to grow – AML/sanctions, LIBOR, Foreign Exchange Currency Cartels and Market Manipulations,...more

The OECD Foreign Bribery Report: 7 Insights to Improve Your Ethics And Compliance Training Program

According to Ernst and Young’s ‘Navigating today’s complex business risks Europe, Middle East, India and Africa Fraud Survey 2013,’ half of workers surveyed across Europe, the Middle East, Africa and India believe bribery and...more

“Is the Current Compliance Model Working?”

An interview with Richard Bistrong. You must read it. Find out about bribery from the front line from someone who has been there, seen it, done it and got the jumpsuit. Originally published on...more

Bribery and the Classroom (not in the Classroom)

“Mr. Bistrong, in the complaint it was alleged that you were a conspirator in bribing foreign officials in multiple countries, such as Nigeria, the UK, and the Netherlands, as well as bribing UN officials. Were there...more

“Corruption: Misunderstanding the Impact.”

As I have shared in prior blogs, from the vantage point of business class and inner city hotels, there is an unhealthy distance and an often ethical unawareness from front lines of international business, when it comes to the...more

Billy the Kid Begins and the GSK China Verdict

According to This Day in History, 139 years ago today, Billy the Kid was arrested for the first time, for theft. Billy the Kid was believed to have been born in New York City and was later taken out west by his mother. ...more

Internal Controls for Third Party Representatives in a FCPA Compliance Program

This week, I am continuing my podcast series, on the FCPA Compliance and Ethics Report, on internal controls in best practices anti-corruption compliance program, under the Foreign Corrupt Practices (FCPA), UK Bribery Act or...more

Justin Bieber Does It Again – Time For Anti Bribery Training To Save The Day

Tsk tsk tsk. Just when I thought I was only going to mention him in one blog post this year, I now have the opportunity to write another. Someone has to do it! Justin Bieber is back in the spotlight and this time it isn’t...more

FCPA Compliance and Ethics Report-Episode 65-World Cup Report-Part I [Video]

The FCPA Compliance and Ethics Report, Episode 65 is out. In this episode, I begin a 4 part World Cup series with Mike Brown, Managing Director of Infortal. In this episode we discuss bribery and corruption of referees and...more

May Flowers for GSK? The Corruption Investigation Deepens

April showers bring May flowers, at least that is the old truism. One place it is decidedly correct is at the RHS Chelsea Flower Show, which began its run as one of the, if not the greatest, annual flower shows in the world...more

A Close Look At Internal Controls

Companies with ineffective internal controls face risks of embezzlement and self-dealing by employees, bribery, export control violations and other possible legal violations. The payment of foreign bribes often occurs in...more

Avoid the Quick Fix: Addressing Government Contracting Ethical Breaches That Can Destroy A Business

For the last 15 years, the Foreign Corrupt Practices Act (FCPA) has garnered the most “compliance” attention by companies and the media due to the severe penalties associated with the bribing of foreign government officials....more

Weekly Recap Ethics News and Trends – March 3, 2014

Public servants with the utmost integrity also need to be aware of what is happening ethically around the state. In today’s climate, every public agency’s image is impacted by the missteps or misconduct of others. Below...more

The Simon-Sting Tour And New Information In Your Compliance Program

This past weekend I saw the first show in a multi-city tour by Sting and Paul Simon. I have never been a big Sting or Police fan but I am a huge Paul Simon fan, in all his musical incarnations. As it was their first show,...more

Weekly Recap Ethics News and Trends – February 3, 2014

Public servants with the utmost integrity also need to be aware of what is happening ethically around the state. In today’s climate, every public agency’s image is impacted by the missteps or misconduct of others. Below...more

Naval Theorists And The Measurement Of Compliance

If are interested in naval history, strategy and tactics, I have a question for you: Are you a disciple of Alfred Mahan or Julian Corbett? If you are a Mahanian, you probably focus on large naval engagements or the great...more

Governor McAuliffe Signs Ethics Executive Order for Virginia

Virginia Governor Terry McAuliffe, on his first day in office, signed Executive Order 2 "Personnel Directive Prohibiting the Receipt of Certain Gifts; Establishment of Executive Branch Ethics Commission" which bans executive...more

Keep Your Hand On The Control

I am continually amazed at the seemingly disparate current events which provide tangible lessons for the compliance practitioner. In an article in the New York Times (NYT), entitled “Hearings on San Francisco Crash Set to...more

Psychopaths In The Board Room? And I Thought The Astros Had A Bad Season

I did not think it would be possible that another Houston professional sports team could under-perform the sad-sack Houston Astros in 2013, who ended the season with a winning percentage of .313%. However the Houston Texans...more

How Straight From The Lion’s Mouth Informs Your Hotline

The symbol of Venice is the Lion of St. Mark. The use of this symbol led to the maxim ‘straight from the lion’s mouth’. This adage came about because the Republic of Venice had its own hotline system where citizens could...more

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